CALIFORNIA AND TEXAS SUPREME COURTS BOTH PROVIDE RELIEF FOR ERRORS ON PETITIONS

On January 24, the Texas
Supreme Court ruled, in two decisions, that candidates who make errors on
their petitions must be given an opportunity to correct these errors. And
on February 16, the California Supreme Court ruled that errors on initiative
petitions that do not pose a realistic threat to the election process should
not keep an initiative off the ballot.

The Texas decisions were
In re Francis, 06-40, and In re Holcomb, 06-42. The California
case was Costa v Superior Court of Sacramento County, S136294. In each
case, some justices dissented.

Texas

In the Texas cases, two
Republicans were restored to the primary ballot. Both were running for Judge
on the Court of Criminal Appeals, and one of the candidates was an incumbent.
Judge Charles Holcomb needed 50 signatures from each of the 14 appellate districts
in the state, but in one district, he was five signatures short.

Robert Francis submitted
a petition in which some of the pages didn’t say which seat he was running
for.

The Texas Supreme Court
put both candidates on the ballot, saying, "We disagree, however, that
invalid signatures cannot be cured…As with other statutes, the consequences
of noncompliance is not necessarily punishment…It would be inconsistent with
the purposes of the Code if some candidates but not others get an opportunity
to cure defects…

"An opportunity
to cure not only complies best with the purposes of the Election Code, but
is also the fairest remedy, and the one most likely to cause the least harm…Punishing
every minor error not only punishes some candidates too much, but also frustrates
the intentions of many voters who willingly signed their petitions…

"The public interest
is best served when public offices are decided by fair and vigorous elections,
not technicalities leading to default. Beginning every election cycle with
lawsuits and publicity about efforts to toss candidates off and on the ballot
sends an unfortunate message that elections are more about civic entertainment
than civic duty."

California

In the California case,
the California Supreme Court said that an initiative involving redistricting
did belong on the ballot, even though the proponents submitted one version
of the initiative to the Attorney General (who writes the title and the ballot
description), and circulated a slightly different version of the same initiative.
The Court found that the differences in the two versions were very minor,
and the mistake was inadvertent. It said, "An unreasonably literal or
inflexible application of constitutional or statutory requirements that fails
to take into account the purpose underlying the particular requirement at
issue would be inconsistent with the fundamental nature of the people’s initiative
power.

"Because the discrepancies
between the version of the initiative measure submitted to the Attorney General
and the version circulated for signature did not mislead the public or otherwise
frustrate or undermine the purposes underlying any of the applicable constitutional
or statutory provisions or threaten the integrity of the electoral process,
we find there was substantial compliance."

In 1978, the California
Supreme Court had ruled that substantial compliance is good enough for candidate
petitions. It had put the incumbent Superintendent of Public Instruction,
Wilson Riles, on the ballot, even though his petition lacked the 65 required
valid signatures.

That case, Riles v
Eu, no. S.F. 23806, only resulted in a one-paragraph unreported decision.
The lower state courts used it as a precedent for a while. For instance, in
1982, a lower state court put a leading Democratic congressional candidate,
Jim Bates, on the ballot even though his circulator admitted that he hadn’t
actually collected the signatures (someone else had collected them but had
not signed the space at the bottom of the petition, as is legally required).
Aguierre v Eu, San Diego Superior Court, no. 483783. Bates, like Riles,
then went on to be elected that year.

As time went on, courts
forgot all about Riles v Eu. When Terry Baum, a California Green Party
candidate for Congress in 2004, tried to cite Riles v Eu, the government
opposition attorney charged there is no such case. That problem won’t occur
with the new Costa precedent, since it is a full-fledged, reported
decision.

Is
Substantial Compliance Workable?

Some election law scholars
deplore the decisions described above, because they feel that only a "strict
compliance" standard is objectively fair to everyone. However, in truth,
it is the "substantial compliance" that will bring equal treatment
to all groups, parties, and candidates. This is because no elections official
ever imposes "strict compliance" on the nominee of a major party,
if the office in question is important enough.

In every state, every
political party is required to certify the names of its nominees for presidential
elector by a certain date. In most states, the parties must also certify the
names of their presidential and vice-presidential nominees. Inevitably, when
a major party is late to perform one of these tasks, the elections officials
themselves overlook the late filing.

Examples are the failure
of both the Democrats and Republicans to timely certify their presidential
nominees in Indiana in 1988; the failure of the Democrats to timely certify
Lyndon Johnson’s name in Iowa in 1964; and the failure of the Republicans
to timely certify George W. Bush’s name in Florida in 2000. In the Indiana
and Iowa examples, after elections officials ignored "strict compliance"
and certified the late names anyway, someone sued to remove the candidates
from the ballot. But the courts approved the lenient treatment. In Iowa, see
Risher v Synhorst, Polk Co. 70105; in Indiana, Fulani v Hogsett,
917 F 2d. 1028 (7th cir.).

There are probably many
more examples, but since the press doesn’t normally monitor the filing of
such arcane documents, it is probable that other instances were never made
known to the public.

By contrast, when minor
parties make the same mistake, elections officials often invoke "strict
compliance". Examples are the failure of the Populist Party to meet the
same deadline in Iowa in 1984, the Libertarian Party to meet the deadline
in both Arizona and in 1996 and Missouri in 1988, and the Constitution Party
in both Vermont and Wisconsin in 2004. In all cases, elections officials ruled
the party’s presidential nominee off the ballot (although, in the case of
the Libertarians in 1996, a state court put the nominee back on).

The behavior of the Massachusetts
Supreme Judicial Court in 1998, 1999 and 2000, also shows the futility of
sticking to a "strict" standard when a major party nominee is at
risk. In 1998 that Court invalidated a referendum petition because some sheets
had a hand-stamp giving the sponsor’s name and address, and the law said all
sheets had to be "an exact copy" of the original sheet, which did
not have such information. In 1999, the same Court invalidated a school voucher
initiative because some of the petition sheets had doodles in the margins.
The Court said, "Exact copy means exact copy." Walsh v Secretary
of Commonwealth, 713 NE 2d 369, at 372.

But in 2000, the same
Court put the Republican nominee for U.S. Senate on the ballot, even though
some of his petition sheets were photocopied with the reverse side upside
down. Robinson v State Ballot Law Commission, 731 N.E.2d 1090. This
time, the Court said it is necessary to look at the purpose of the law, and
no good purpose would be promoted by a strict construction rule.

Frequent
Victimization

Minor party and independent
candidates regularly fail to appear on ballots as a result of minor, technical
paperwork problems. In 1972, the nominees of the American Independent and
Peoples Party (Congressman John Schmitz and Dr. Benjamin Spock) were kept
off the Indiana ballot because they were late to file a loyalty oath. Ralph
Nader was kept off the 2004 Oregon ballot because the page numbers on his
petitions weren’t consecutive, and because some of his circulators initialed
some sheets instead of using full signatures.

David Bergland, Libertarian
nominee in 1984, was kept off the South Dakota ballot because his petitions
said, "If elected, we will qualify and serve in those offices" instead
of "We are eligible for the offices for which we are candidates. If elected,
we will qualify and serve in those offices."

The Ohio Libertarian
Party was kept off the ballot in 2004 because its petitions said, "Whoever
commits election falsification is guilty of a felony of the fifth degree"
instead of "The penalty for election falsification is imprisonment for
not more than six months or a fine of not more than $1,000 or both".

Eugene McCarthy was kept
off the New York ballot in 1976 because his petition sheets didn’t segregate
signers by congressional district as well as by county.

The Unity Party of New
York lost its U.S. Senate nominee in 1982 because he submitted a photocopy
of his notarized declaration of candidacy on the deadline, instead of the
original. The Socialist Workers Party lost its nominee for Mayor of Cleveland
in 1971 for the same reason.

The Citizens Party lost
its 1984 nominee for U.S. House in Minnesota because his declaration of candidacy
was late, even though his petition was on time. Many independent candidates
in Alabama and Arkansas have been kept off the ballot because they didn’t
file campaign finance documents at the same time they filed their petitions.

The Natural Law Party
was kept off the Georgia ballot in 1996 because one of the party’s volunteer
notaries who had notarized thousands of signatures had herself circulated
a few sheets of the petition. The same problem kept the Constitution Party
off the ballot in that state in 1996 as well.

State courts in some
states, notably Ohio and New York, still insist on "strict construction".
On October 24, 2005, New York’s highest state court ruled in McGuire v
Gamache, 840 N.E.2d 107, that an independent candidate should be kept
off the ballot because her circulator crossed off one line in the circulator’s
statement. That one line said that the circulator is eligible to vote for
the candidate.

In 2004, the law requiring
such a circulator to live in the district had been declared unconstitutional.
The circulator was aware of that, and didn’t live in the district, and didn’t
wish to commit perjury by signing an untrue statement. Because elections officials
had never updated the form to take account of the 2004 court ruling, the circulator
himself altered the form. The Court still knocked the candidate off the ballot,
saying that the candidate could have been on the ballot if she had arranged
for the circulator to appear at the court hearing. The vote was 5-2. It is
very difficult to believe that the Court would have come to the same conclusion
if the candidate had been a major party nominee for a major office.

California and Texas
are the two most populous states. In both states, the unworkable "strict
construction" standard has been set aside. It would be desirable if state
courts in other states would follow their lead, especially Ohio, New York
and Pennsylvania.

ALASKA
GREENS WIN

For the second time,
a lower Alaska state court has prevented elections officials from removing
the Green Party from the ballot. Green Party of Alaska v State, 3AN-05-10787.
The recent order is dated February 8. A similar order had been won on November
3, 2003. The validity of the definition of "political party" will
be decided in a few months.

The Alaska courts seem
to believe, wisely, that the vote test should include all the statewide races.
Yet the legislature persistently writes the definition so that only one statewide
office counts. The existing law says that in gubernatorial years, only the
vote for Governor counts. So if a party fails to get 3% for Governor, but
does get it for U.S. Senate or U.S. House, or both, it fails the vote test.

The existing law also
applies a vote test in presidential years. In presidential years, only the
vote for U.S. Senate counts. If there is no U.S. Senate seat up that year,
then and only then does the vote for U.S. House count.

It seems obvious that
if the vote for U.S. Senate or U.S. House counts in presidential years, there
is no reason why it shouldn’t count in gubernatorial years as well.

Other states in which
the vote test is for only a particular office (in any given election year)
are Arizona, Arkansas, Indiana, Iowa, Kentucky, Maine, Maryland, New Hampshire
in presidential years, New Mexico, New York, North Carolina, Ohio, Oklahoma,
Rhode Island, South Dakota, Tennessee, Wyoming in presidential years, and
West Virginia.

This is the first lawsuit,
in any state, challenging a definition of "political party" on the
grounds that the vote for any statewide office ought to count. In 1980,
the New York Libertarian Party polled over 50,000 votes for president. New
York law says a party is a group that polled 50,000 votes for Governor; no
other office counts. The Libertarian Party filed a lawsuit, but sued the wrong
defendant, so the case was dismissed and the party never returned to court.

NEW
YORK BALLOT ACCESS VICTORY

On January 27, U.S. District
Court Judge John Gleeson struck down the ballot access law on how candidates
get on primary ballots, for delegate to the party’s judicial nominating conventions.
Lopez Torres v N.Y. Bd. of Elections, 04-cv-1129 (e.d). These conventions
are to nominate party candidates for Judge of the Supreme Court. New York
elects Supreme Court judges on a partisan basis. The state is divided into
twelve districts for that purpose, and each district elects its own Supreme
Court Judges. In New York, the Supreme Court is not the highest state court;
the highest state court is the Court of Appeals, and its members are appointed.

Judicial districts are
comprised of between nine and twenty-four Assembly districts. The law requires
500 signatures per Assembly district. Therefore, slates of candidates for
delegate need between 4,500 signatures, and 12,000 signatures. The evidence
showed that no slates ever qualify, unless they are backed by the party organizations.

Major newspapers praised
the decision. Although it is being appealed, few expect it to be reversed.
Judge Gleeson said that until the legislature acts, party nominees for Supreme
Court Judge will be chosen directly in primaries. The State Senate passed
SB55A on February 13, which provides that candidates for Supreme Court Judge
should be nominated directly in primaries. However, the bill has little chance
in the Assembly, at least until the state’s appeal to the 2nd circuit
is exhausted. Democrats control the Assembly, and they like the old system.

"TOP-TWO"
HEARING

On February 6, the 9th
circuit heard the state’s appeal, in the "top two" initiative case,
Washington State Republican Party v Logan, 05-35780. The argument went
well for the three political parties that challenged the initiative. Two of
the three judges expressed skepticism toward the law, and the third judge
seemed neutral.

PEACE
& FREEDOM WINS BALLOT FIGHT

On January 31, Bruce
McPherson, California’s Secretary of State, issued a press release saying
the Peace & Freedom Party is no longer a qualified party. However, on
February 3, he reversed himself, and said the party is qualified after all.

The party was holding
a mass protest rally on the steps of the State Capitol, when the February
3 ruling came down. If the state had not given in, the party would have filed
a lawsuit, which almost surely would have won. The party has 59,193 registrants,
far more than the one-fifteenth of 1% needed for a party to remain on the
ballot, although less than the 77,389 needed for a new party.

The law defining "political
party" is badly worded. McPherson made his initial decision before researching
how the law has been interpreted in the past.

OREGON
BAN ON PAYING PER SIGNATURE

In 2002, Oregon made
it illegal for initiative circulators to be paid on a per signature basis.
On February 22, the 9th circuit tentatively upheld the law. Prete
v Bradbury, 04-35285.

Oregon regulations say,
"Payment cannot be made on a per signature basis. Allowable practices
include: paying an hourly wage or salary, establishing either express or implied
minimum signature requirements for circulators, terminating circulators who
do not meet the productivity requirements, adjusting salaries prospectively
relative to a circulator’s productivity, and paying discretionary bonuses
based on reliability, longevity and productivity."

The plaintiffs provided
little evidence that the law injures them, but the state provided evidence
that the ban is useful in combating fraud. The 9th circuit said,
"We do not hold that the law is facially constitutional. Rather, we hold
that the district court did not clearly err in determining plaintiffs failed
to establish that the law imposes a severe burden."

CREATIVE
NEW IDEA FOR ELECTORAL COLLEGE REFORM

On February 23, a plan
to win a Constitutional Amendment for direct popular election of the president
was launched by National Popular
Vote. The movement is headed former Congressman John B. Anderson of Illinois,
former U.S. Senator Birch Bayh of Indiana, and former Congressman John Buchanan
of Alabama.

The U.S. Constitution
lets states choose their presidential electors any way they wish. National
Popular Vote suggest that state legislatures pass laws that provide that the
state will choose presidential electors who are pledged to vote for whichever
presidential candidate receives the greatest number of popular votes, nationwide.
Such a bill has already been introduced in Illinois, SB2724.

These laws would only
go into effect when enough states to control a majority in the electoral college
had passed such laws.

OHIO
DEMOCRATIC BALLOT ACCESS WOES

Ohio State Senator Charlie
Wilson failed to gather the needed 50 signatures to get on the Democratic
primary ballot for U.S. House, 6th district. He is considered the
front-runner, and has $400,000 in his campaign treasury. He submitted 96 signatures,
but only 46 are valid; many signers don’t live in the district. He can still
be a write-in candidate in the May 2 primary, or he could submit 2,240 signatures
by May 1 to be an independent candidate.

MORE
LAWSUIT NEWS

California: on
March 8, the State Supreme Court will hear the case over whether Prop. 60
is part of the Constitution. Californians for an Open Primary v Shelley,
S126780.

New Jersey: on
February 9, the Appellate Division revived a lawsuit to require a paper trail
for voting machines. The 2005 legislative session had mandated a paper trail,
but made it conditional on whether the manufacturers of these machines can
comply. The Court said the case is not moot, since no one knows for sure what
the makers of these machines will do next, and sent it back to the lower court
for more fact-finding. Gusciora v McGreevy, A-2842.

North Carolina:
the Green Party is joining the Libertarian Party’s ballot access case, and
will be represented by the ACLU.

Ohio: on February
8, a federal court said the dispute over the presidential recount of 2004
is moot. The issue had been whether the recount should have started as soon
as the recount fees had been paid, or whether the state had a right to postpone
the recount until the first count was certified. Rios v Blackwell, 3:04-7724,
n.d. On February 17, plaintiffs asked for a rehearing, pointing out that the
same procedures still exist.

Pennsylvania:
on February 2, a U.S. District Court heard witnesses in the ballot access
case filed by the Green and Constitution Parties, Rogers v Cortes, 06-66,
m.d. Plaintiffs put on many witnesses, but the state only put on one witness.
The judge then set a schedule for each side to file briefs on the legal issues.
Plaintiffs have already filed theirs, but the state has obtained a delay until
mid-March for its brief.

Washington: Ruth
Bennett, Libertarian nominee for Governor in 2004, is suing King Broadcasting
Company for excluding her from primary season debates (she had a primary opponent),
as well as general election debates, that year. The case is based on state
law, not the U.S. Constitution. Bennett v Belo Corp., 05-2-27309, King
Co. Superior Court.

2006
PETITIONING

The New Mexico Libertarian
petition seems not to have enough signatures, but the state will let the party
collect more; the deadline is April 4. The Working Families Party has 1,500
signatures in South Carolina and 2,000 in Oregon. The Constitution Party is
almost finished in Montana. The Green Party is making headway in Arkansas,
Indiana and Nebraska. So is the New Hampshire Libertarian Party. John Dashler,
independent for Georgia governor, has 3,500. Ben Westlund, independent for
Oregon Governor, has just started.

LEGISLATIVE
NEWS

Arizona: HB 2492
moves the primary from September to August. It also sets a June 15 deadline
for independent candidate petitions, which is a few days improvement over
the existing law, in which the deadline ranges from June 9 to June 15, depending
on that year’s calendar.

Maryland: SB 292
would provide for Instant-Runoff Voting in all partisan elections, and had
a hearing on February 16. Testimony was overwhelmingly in favor.

Michigan: HB 5082
passed the House Election Committee on February 22. It eases the deadline
for a qualified minor party to certify the name of its presidential candidate,
from one day after the party’s national convention, to 60 days after.

New Mexico: HB453,
which would have moved the deadline for minor party nominee petitions from
mid-July to early June, failed to pass.

South Carolina:
H4331 bans fusion. It passed the House on January 31, but seems to lack Senate
support.

Washington: SB
6236 would move the primary from September to August. It also moves the petition
deadline for minor party and independent candidates (for office other than
president) from July to June. It moves the minor party and independent presidential
deadline from early September to late July. It passed the Senate on February
1, and the House Rules Committee on February 20.

MOST
RECENT INDEPENDENT GUBERNATORIAL CANDIDATE ON BALLOT

State

Year

Ballot Label

Candidate

Vote

Percentage

Alabama

1970

Independent

A. C. Shelton

75,679

8.85%

Alaska

1978

Alaskans for Kelly

Tom Kelly

15,656

12.34%

Arizona

2002

Independent

Richard Mahoney

84,947

6.93%

Arkansas

1938

Independent

Charles S. Cole

12,077

8.68%

California

2003

Independent

Ariana Huffington

47,505

.55%

Colorado

1978

Tea Party’78

E. L. Roy Peister

13,990

1.70%

Connecticut

1990

A Connecticut

Lowell Weicker

460,576

40.36%

Delaware

- -

- -

- -

- -

- -

Florida

2002

Independent

Robert Kunst

42,039

.82%

Georgia

1942

Independent

Foreman

687

1.09%

Hawaii

- -

- -

- -

- -

- -

Idaho

1998

Independent

Peter Rickards

12,338

3.24%

Illinois

2002

Independent

Marisellis Brown

23,089

.65%

Indiana

- -

- -

- -

- -

- -

Iowa

1998

Nom. by Petition

Mark Kennis

2,006

.21%

Kansas

1990

Independent

Christina Kline

69,127

8.82%

Kentucky

1983

Citizens United

Nick McCubbin

14,347

1.39%

Louisiana

2003

(blank)

Patrick Landry

7,195

.53%

Maine

2002

Independent

John M. Michael

10,612

2.10%

Maryland

1966

Independent

Hyman Pressman

90,899

9.89%

Massachusetts

2002

Independent

Barbara Johnson

15,335

.70%

Michigan

- -

- -

- -

- -

- -

Minnesota

2002

Independent

Booker Hodges

9,698

.43%

Mississippi

1999

Independent

Helen Perkins

6,005

.79%

Missouri

1976

Non-Partisan

Leon Striler

4,215

.22%

Montana

- -

- -

- -

- -

- -

Nebraska

1974

By petition

Ernie Chambers

24,320

5.39%

Nevada

2002

Independent

Jerry L. Norton

5,543

1.10%

New Hampshire

2000

Independent

Mary Brown

35,904

6.36%

New Jersey

2005

Edu not Corrupt’n

Hector Castillo

29,452

1.29%

New Mexico

- -

- -

- -

- -

- -

New York

2002

Marijuana Reform

Tom Leighton

21,977

.48%

North Carolina

- -

- -

- -

- -

- -

North Dakota

2004

Independent

Roland Riemers

4,193

1.35%

Ohio

2002

Independent

John Eastman

126,686

3.92%

Oklahoma

2002

Independent

Gary Richardson

146,200

14.12%

Oregon

1990

Independent

Al Mobley

144,062

12.95%

Pennsylvania

1942

United Pension

John Haluska

7,911

.31%

Rhode Island

1992

Independent

J. Staradumsky

1,535

.36%

South Carolina

- -

- -

- -

- -

- -

South Dakota

1934

Independent

Knute Walsted

2,190

.75%

Tennessee

2002

Independent

Edwin Sanders

7,749

.47%

Texas

- -

- -

- -

- -

- -

Utah

1988

Independent

Merrill Cook

136,651

21.05%

Vermont

2002

Independent

Cornelius Hogan

22,353

9.71%

Virginia

2005

Independent

Russell Potts

43,953

2.22%

Washington

1972

Txpyrs to cut Tax

Vick Gould

86,843

5.90%

West Virginia

1920

Independent

Sam Montgomery

81,330

15.90%

Wisconsin

2002

Independent

Ty Bollerud

2,637

.15%

Wyoming

1958

Economy

Louis Carlson

4,979

4.42%

State
legislators, or state executive office-holders, or ex-state legislators,
are independent candidates for Governor this year in Alaska, Maine, Oregon,
and Texas. It is unusual to have so many seasoned politicians running for
Governor as independent candidates, all at once.

The chart on page five
shows the last instance when an independent candidate appeared on a government-printed
ballot in each state. Nine states have never had such a candidate on a government-printed
ballot.

For purposes of the chart,
"independent candidate" means a candidate who used the independent
candidate procedures. Thus, some of the "independent candidates"
on the chart were legally independents, but in reality the nominees of unqualified
parties. This is true of North Dakota (where the listed candidate was really
a Libertarian) and South Dakota (where the listed candidate was really the
Communist nominee).

For the minority of states
in which the ballot access procedures for new parties and independent candidates
are merged into a single procedure, the chart assumes that an "independent
gubernatorial candidate" is one who has chosen a ballot label that no
other candidate for any other office is using (except that the independent
gubernatorial candidate sometimes has a lieutenant-governor running-mate with
the same label, of course), anywhere else in the state or nation. It is always
not easy to differentiate minor party candidates from independent candidates
in states with this legal structure, and this seemed the best method.

PROHIBITION
FIGHT GOES TO COURT

George Pennock, a supporter
of the Prohibition Party who died more than fifty years ago, left a legacy
to his party. It is a trust, which pays the national party approximately $8,000
per year. The two national factions of the party each seek to receive this
income. A state court in Delaware County, Pennsylvania is handling a lawsuit
to settle the matter. PNC Bank v Pletten, 114-1937. The judge has been
trying to encourage a compromise settlement.

VERMONT
PROGRESSIVES

The Vermont Progressive
Party had hoped to run one of its senior state legislators, David Zimmerman,
for U.S. House this year. However, Congressman Bernie Sanders exerted his
influence to persuade Zimmerman to drop out, and on February 15, Zimmerman
did drop out. Democrats in Vermont are supporting Sanders as an independent
for U.S. Senate, and Sanders has reciprocated by helping the Democratic nominee
for U.S. House. Zimmerman will run for re-election to the legislature.

RICK
JORE EXPECTS 2-WAY RACE

Rick Jore, the only Constitution
Party state legislator ever, and who lost his battle for re-election in 2004
in a virtual tie, is running for a new term in the Montana 12th
State House district. Although it isn’t certain, it is likely that he will
be the only opponent of the Democratic legislator who defeated him. Republicans
don’t expect to run anyone.

GEORGIA
LIBERTARIAN DROPS OUT

Jay Fisher, a Georgia
Libertarian, had announced that he would try to be the first party nominee
on the Georgia ballot for U.S. House since 1943 (other than Democratic and
Republican nominees). However, at the time he announced, he thought he needed
approximately 15,000 signatures. Actually he needs 19,377. In addition, his
employer, the state of Georgia, informed him that even though there is no
written policy preventing state employees from running for Congress, in practice
it is frowned on. So he dropped out.

FORMER
MAYOR WILL BE GREEN CANDIDATE FOR U.S. HOUSE

Bill Paparian, who was
a city councilmember and mayor of Pasadena, California, between 1987 and 1999,
will be the Green Party candidate for Congress in the 29th district.
The incumbent Democrat, Adam Schiff, is running for re-election. In 2004 the
vote was Democrat 133,670; Republican 62,871; Green 5,715; Libertarian 4,570.

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